Coordinating Asset Owner and PSIRT for CRA Vulnerability Recognition: Evidence-Based Mechanisms from Coordination Theory

Abstract

The EU Cyber Resilience Act (CRA) requires manufacturers to provide early warning within 24 hours, detailed notification within 72 hours, and final reporting within 14 days after corrective measures become available, upon becoming aware of actively exploited vulnerabilities (Article 14). However, the evidence necessary to establish awareness exists primarily in asset owner environments, and asset owners bear no reporting obligation. This creates a structural coordination challenge: manufacturers require evidence they cannot independently access, and fixed reporting deadlines commence upon awareness. This study applies Malone & Crowston's coordination theory to identify three dependency relationships: bidirectional knowledge asymmetry (producer-consumer relationship) between asset owners who hold evidence and PSIRTs who hold product knowledge; time allocation (shared resource) under fixed reporting deadlines (24h/72h/14d); and misalignment between different objectives (task-subtask dependency). We propose a three-layer mechanism for managing these dependencies. C0 (Reachability) provides reporting channels. C1 (Evidence Coordination Profile) decomposes Article 3(42) awareness definition into five propositions and structures evidence into four categories (E1-E4), enabling the establishment of awareness and phased reporting. C2 (Incentive Design) converts asset owners’ voluntary cooperation into organizational security improvement through three benefits. These three mechanisms mutually reinforce each other to achieve continuous coordination. Theoretically, this extends the coordination theory to regulatory compliance contexts in which coordination is voluntary. Practically, it provides implementable guidance for manufacturers facing CRA enforcement by 2027.

Keywords: Cyber Resilience Act, PSIRT, Coordination Theory, Vulnerability Recognition, Reporting Obligation, Voluntary Cooperation, Evidence-Based Coordination

DOI: 10.54941/ahfe1007041